You can't look at metalworking's materials and processes
any more without considering their impact on the human operator and on
the environment-whether inside or outside of the manufacturing facility.
And the closer you look, the more complicated government regulations
have made the business life of metalworking companies.

"Four or five years ago metalworking managers had to worry
about four of five regulations; today there may be 20 or more that
affect their manufacturing operations," says Randy Junkins,
president, Junkins Engineering Inc, a Morgantown, PA-based environmental
engineering consultant.

And the heat is on as the Environmental Protection Agency (EPA) and
the Occupational Safety and Health Administration (OSHA), increase
monitoring and enforcement of regulations, especially on small and
medium-sized companies, says Mr Junkins. Last year, for example, OSHA
fines jumped 700% and instances of substantial fines for not submitting
the right paperwork by smaller companies occurred. And the threat of
criminal prosecution for management and supervisory personnel is a real
possibility.

Finding out what to do

The impact of environmental regulation on smaller and medium-sized
companies isn't unexpected. They are least able-in terms of human
and financial resources-to deal with the proliferation of regulations
aimed at cleaning up the environment's twin streams: 1) ambient
in-plant air and exhaust air; 2) fluids used in metalworking processes
and outfall wherever run-off leaves a manufacturing property site.

The problem is often one of simply knowing what the regulations
are, what they require, when and how to comply, and how to get help in
complying. That's why the National Tooling & Machining
Association, Ft Washington, MD, devotes a considerable amount of its
resources to translating the complicated rules into plain English and
developing responsible compliance strategies. The principal body of law
that will affect most tooling and machining companies, for example, is
the "small quantity generator (SQG)" provision of RCRA (the
Resources Conservation and Recovery Act) as enforced by the EPA, says
NTMA.

Though SQG provisions may relieve smaller companies of some of
RCRA's burdens, others can pose major problems. Because these firms
work in batches of only a few parts at a time, and each job is usually
of dissimilar material, material safety data sheets (MSDS) or chemical
analysis specifications are usually not available, particularly for
small lots on a subcontract basis. Waste hauler's fees and required
chemical analysis costs can easily outstrip revenues for small batch
work, says NTMA.

NTMA feels that simply publishing complicated proposals and final
rules in the Federal Register and requiring compliance and repetitious reporting and record-keeping are onerous and unreasonable for smaller
companies.

"The EPA is just doing what it knows how to do best-writing
regulations hand-over-fist," says William E Ruxton, NTMA's
manager/technical department. He says that one of the most important
single issues facing companies today is compliance with EPA storm water
regulations.

NTMA expects the cost of compliance for small companies to be
"considerably higher" than EPA estimates. A major factor is
the cost of consultant services to prepare applications. Another factor
is that a more flexible general permit (one of three permit options open
to companies) was not available in many metalworking states before the
deadline for group or individual permits was reached. NTMA says that
this affected more than half of the industry's small manufacturing
companies.

Airborne pollutants

What's in the air is equally of concern both inside and
outside of plants. While EPA deadlines for final phase-out of certain
chemicals important to metalworking processes have been set, their
replacements are in the process of being evaluated. Materials will have
to meet the rigid test of their ozone depleting potential (ODP) and
global warming potential (GWP) under EPA's Significant New
Alternatives Policy (SNAP) program.

Under the EPA's current timetable, chlorofluorocarbons (CFCs),
halons, carbon tetrachloride, and methyl chloride will be phased out by
the year 2000 and methyl chloroform by 2002-unless these dates are
advanced by more dire reports on the rate of ozone depletion. All, at
one time or another, have been important to metalworking and machining
processes.

Airborne contaminants are very much a part of machine-tool
operation and accompanying processes and can be generated as gases,
vapors, fumes, and dusts, according to Gary M Hutter PhD, president of
Triodyne Environmental Engineering Inc, Niles, IL:

Conditions can be dramatically altered, says Dr Hutter, by changes
in the formulation of fluids and coolants by manufacturers, by the
mechanical action of machines on oil-creating mists, and even by making
buildings more air-tight, thus altering the amount of dilution of air
contaminants. Simply adding machine tools-each with its own exhaust
hood- to an existing air-handling system without increasing its
air-handling capacity may drop exhausting efficiency below needed
levels.

The greatest impact, however, could be felt if the exhaust levels
of a plant-for hydrocarbons, for examplereaches the threshold level.
Once subject to compliance guidelines, the cost of compliance can be
substantial as emissions must be reduced by 90%, not just enough to come
in under the threshold levels.

Materials management

The key to compliance often will be controlling processes or
changing materials used in the processes. Here are two examples of how:

At Pfauter-Maag Cutting Tools, Loves Park, IL, environmental
considerations continue to impact fume-producing salt baths used to
control the rate of cooling in hardening gear hobs and milling cutters.
"There is the possibility that salt baths for which there is no
acceptable commercial alternative today will be eliminated in the
future," says James Hursh, vice president-manufacturing. Similarly,
no acceptable substitute exists for Freon, which is used as a highly
efficient cleaning solvent and is slated for phase-out in the mid-1990s,
Mr Hursh says. Using Freon carries with it a substantial cost because
about $900 of the $1400 per barrel cost is for disposal.

An agreement by Dow Chemical to promote new ultra-low-emission
solvent cleaning equipment in the US underscores the importance of
changing equipment, as well as materials. Designed to tougher European
standards, the closed-top vapor degreasing equipment from Durr
Industries is said to reduce solvent emissions by up to 99% when using
chlorinated solvents such as methyl chloroform, trichloroethylene,
perchloroethylene, and methylene chloride. Two of the units handle small
parts in baskets; the third can handle parts up to 14 ft long weighing
up to 3300 lb.

Fluid management

Metalworking managers have to take a global view of their usage of
metalworking fluids, says William H Vickers, manager of metalworking
marketing, EF Houghton & Co, Valley Forge, PA. Selection of fluids
cannot be made without considering all aspects of use, including the
potential liabilities to operator health and safety and the environment,
Mr Vickers says. His company, for example, doesn't use any
"high liability" materials in its own manufacturing processes.

A little attention to the potential of pollutants can avoid
problems in treatment. There are two general types of
pollutants-physical and chemical- encountered in fluids used for such
diverse metalworking operations as cutting, grinding, quenching,
forming, rolling, cleaning metal, and preventing rust, says Mr Vickers.

* Avoid disposal of fluids and adhere to a prescribed maintenance
program-solution life can be extended by keeping sumps clean and free of
bacteria;

* Reclaim the fluid's oil content which can be reused, sold,
or added to heavier fuel oil to generate heat or power;

* Use biodegradable water-soluble products that do not contain
priority pollutants;

* Check with the fluid supplier to determine whether it has a waste
treatment or technical service group that can assist in solving
fluid-disposal problems;

Ensure that supplier's products have evaluated Chemical Oxygen
Demand (COD) and Biological Oxygen Demand (BOD) values-important in
determining their impact on water and wastewater systems.

TQM needed

"The approach that is needed is a far cry from the old
practice of delivering a drum of coolant, lubricant, drawing fluid or
metal-cleaning compound, and walking away, leaving the customer to cope
with monitoring the performance, life, inventory, and disposal of the
fluid," says Alan Jarrard, business manager-metalworking, Oakite
Products Inc, Berkeley Hts, NJ.

The rising prices of fluids, soaring costs of disposal of spent
fluids, and the higher costs of the labor for cleaning fluid systems
have put a premium on increasing service life of fluids, Mr Jarrard
says. Also, customers are more quality conscious and worker environments
are under more intense scrutiny by the EPA and OSHA.

Mr Jarrard believes that what is needed is the application of total
quality management (TQM) and SPC techniques in the management of fluids.
Oakite's surveys of metalworking operations have revealed that each
type has its own set of problems:

In metal stamping and drawing, the primary concerns are production,
die life, cost effectiveness, cleanability of parts, and disposal of
spent fluids. In grinding and machining, the chief considerations are
production costs and the emphasis on environmental concerns. Machine
downtime because of short tool life, parts finish problems, frequent
sump cleanout, operator discontent, and high volumes of effluents are
the most costly elements.

Mr Jarrard recommends a team concept approach to fluids management.
For an engine maker, a typical program assigned a specialist to each
area: machine tools, coolants and lubricants, cleaners and coatings,
laboratory analysis, metering equipment, traffic management for
inventory control, and disposal management.

Other considerations

While a final decision is awaited from EPA on the status of oil,
i.e. is it a hazardous waste or not, or only when mixed with hazardous
materials, synthetic coolants continue to make headway. According to
Robert Rauth, president of Pillsbury Chemical & Oil Div, Novamax
Technologies (US) Inc, Detroit, synthetics eliminate the use of sulfur
and chlorine and alleviate environmental impact/discharge concerns as
well as potential operator health and safety problems.

Although coolant manufacturers are working hard to eliminate all
use of chlorine (two types have been identified as potential
carcinogens), it will be some time before these additives are completely
replaced. Similarly, coolant producers are looking for replacements for
sulfur which generates unpleasant odors.

Mr Rauth contends that synthetic fluids contain no toxic or
hazardous substances and no irritants, offer 90% biodegradability, and
can be easily broken down in conventional plant waste treatment systems.
Because they last much longer (due to rejection of tramp oil), there is
much less waste fluid to dispose of.

Changes that are coming to metalworking may be coming a little
slower than other industries, however. The phase-out of CFC-113 and
methyl chloroform for use as cleaning solvents is still challenging the
industry to find alternatives.

"While the electronics industry has been able to move quickly
to alternative cleaning products or processes, changes in metal cleaning
products or processes may take longer," says Steve Risotto,
executive director of the Center for Emissions Control, Washington, DC.
"It's not that alternatives are not available, but the
cleaning applications for these two solvents are so many and varied that
alternatives almost have to be evaluated on a case-by-case basis."

The Center is developing a control option document for solvent
cleaning emission control.

To stay on top of environmental regulations, Randy Junkins suggests
that metalworking companies work closely with their trade associations,
get their trade associations involved in environmental matters, if they
aren't already, and have a preliminary environmental audit done of
their plant operations.

Hazard communication checklist

Rate your hazard communications program required under OSHA's
Right-to-Know rules by this checklist from NTMA:

Ultrafiltration system, the UF 250 T, provides waste minimization
membrane technology to meet the needs of customers who wish to process
up to 250 gal of oily wastewater a day without using chemical additives.
Sanborn Inc, Wrentham, MA, circle 309.

Gas and liquid sample filters operate at 99.9999% efficiency and
protect analyzers from sample impurities which are the most frequent
cause of maintenance problems for instruments in an industrial
environment. Balston Inc, Haverhill, MA, circle 313.

Oil skimmer removes up to 1 1/2gal of floating oil per hour from
the surface of fluids in cleaning system tanks. Advanced Curing Systems
Inc, Chicago, IL, circle 317.

Acro Kut 9050, a new synthetic cutting fluid for use in cutting and
grinding steel and cast iron where a fine surface finish is required, is
formulated for easy waste treatability using conventional
chemical/biological methods as well as 90% biodegradability. Pillsbury
Chemical & Oil Div, Detroit, MI, circle 314.

Alternative metal cleaning system called PartsPrep[TM] replaces
CFCs, solvents, and vapor degreasing with a system that consists of
spray or immersion cleaners, a two-stage rinse cycle and drying stage to
remove deposits of carbon, smut, grease, lubricants, drawing and buffing
compounds, and epoxy resins from most metals. ISP Management Co Inc,
Wayne, NJ, circle 316.

Tramp trap is a patented material that absorbs up to 32 times its
weight in tramp oils from synthetic coolants. The trap can be cleaned
using any common degreasing agent and reused for three to six months.
Pace Technologies, Comstock Park, MI, circle 321.

The Barrett Sludge Extractor recovers up to 85% of the oils or
coolants present in wet sludge leaving the user with reusable fluids and
easy-to-dispose dry sludge. Available in six models and able to handle
loads up to 425 lb. Barrett Centrifugals Inc, Worcester, MA, circle 315.